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Debt/equity: comments on recent developments, overseas experiences and Section 974-80 paper

Published on 17 Nov 05 by NEW SOUTH WALES DIVISION, THE TAX INSTITUTE

This paper covers:

  • the distinction between debt and equity
  • comments on the US, UK and Canadian experience
  • current issues:
    • effect of solvency clauses for project finance, lower tier 2 capital
    • what if you cannot institute winding-up proceedings on a default by a company?
    • the effect of conversion rights and options, including TD 2004/D76
  • the ambit of section 974-80.

Author profiles

Martin Fry FTI
Martin has been a Partner in the Allens Tax Group for 20 years and in that time has been extensively involved in advising resource companies, infrastructure projects, banks and IP intensive businesses. In recent years he has focused on contentious cross border issues, both from a litigation perspective and in alternative dispute resolution. - Current at 30 November 2020
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Brad SCHWARZ
Brad, a Senior Associate with Allens Arthur Robinson, practices in international and corporate taxation. He has experience in a wide range of income tax matters including sales, acquisitions and restructures, financing arrangements, and advising companies on the impact of tax consolidation in M&A transactions.
Current at 23 July 2004
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This was presented at Corporate Tax Intensive - Tough Tax Topics .

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